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Privacy Policy

(‘We’) Edinburgh Alternative Finance Limited (trading as LendingCrowd) are committed to protecting and respecting your/the Borrower’s/Lender’s privacy.

IMPORTANT NOTICE

Please read this policy carefully as you are bound by it, and we particularly direct Borrowers to Clause 4(a) – credit reference agencies

Additionally, if you choose to submit or otherwise provide to us any information relating to another individual, whether or not that individual is financially connected to Borrower, you expressly warrant to us that you have obtained that individual’s prior written consent to the collection, use and processing of their information, in accordance with this privacy policy.

This policy (together with our Terms of Use and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. By ticking the acceptance box when signing up to use our Services, and by your continued use of the Services, you agree to be bound by this policy as updated from time to time.

  • Who we are
  • Your rights to access and/or amend data held and opt out of consenting to uses of
    your data
  • What data we collect
  • What we do with this data and our use of credit reference agencies
  • Our rights to use your information for publicity purposes
  • Where we store this data
  • How long we store your data for
  • Steps taken to keep your data safe
  • Our Cookie policy
  • Our right to amend our policy

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1. Who we are

Edinburgh Alternative Finance Limited is the data controller (for the purposes of the Data Protection Act 1998). We make an annual notification to the Information Commissioner (our registration number is ZA052875).

We are a private limited company incorporated in Scotland, having Company Number SC468392, and having our registered office at 23 Manor Place, Edinburgh EH3 7DX. We are authorised and regulated under by the Financial Conduct Authority with Firm Reference Number (FRN) 670991.

We provide a peer-to-peer lending platform online at www.lendingcrowd.com (the “Services” referred to within this policy) Some of our terms will make reference to our Group Companies and any reference in this policy to “us” or “we” or “our” will include our Group Companies. As a growing organisation we may have a number of subsidiary companies (“Group Companies”) that operate some of our sites on our behalf or provide services for us to enable us to provide the Services to you. For data protection purposes, these companies are called data processors. Our Group Companies are all/will all be wholly/majorly owned by us.

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2. Your rights to access/amend the data we hold on you & opt out

Accessing the data we hold on you

If you want to know what data we hold on you, you have a legal right to obtain this information from us. You can make a Subject Access Request at any time, in writing, by following this simple process. By law, we have up to 40 days to respond to you and reserve the right to make a small charge for this service.

To make a Subject Access Request please write to us at our registered office, for attention of Data Protection Officer, enclosing a photocopy of a photographic ID (e.g. passport or driving licence) and utility bill (to provide proof of your address). This is to ensure we only send your data to you, or a third party that you expressly authorise in writing to deal with for you.

Amending/correcting the data we hold on you

If you want to amend the data we hold that’s also very easy to do. We want to make sure we have everything right so please simply contact us to make any amendments to our records.

Changing your consent and opting out

It’s ok to change your mind about what data you are allowing us to keep and what you don’t want us to keep. You can contact us to make any amendments to your consents. We have to advise you however, that opting out of some data processing/storage will result in a loss of functionality of the sites and a reduced user experience.

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3. What information we collect about you (borrowers)

We may collect and process different types of information about you. Some of this data is considered to be Personal Data (that means you can be identified by it including Sensitive Personal Data) and Anonymous Data (that is data that you cannot be identified from).

(a) Information we collect when you sign up to our Services and make Loan applications

For all Borrowers, and all directors of Borrower companies we will collect your personal details including but not limited to your real name, user name, address, telephone, email address, date of birth, bank accounts and any other information you submit when you create a Borrower account and make Loan applications.

In respect of your business we will additionally require full disclosure of business information including bank accounts, company incorporation and filing history, trading history and accounts, financial history and any other relevant information required to build a risk profile of your business. You warrant that all information so disclosed is true and accurate.

(b) Information we collect from third parties about Borrowers

We may collect information about you from third parties to verify your identity and for fraud prevention. We collect information about Borrowers’ (including their directors’, shareholders’ and/or members’) identity and credit history/score from credit reference agencies including CreditSafe. We use third parties such as sub-contractors in technical functions, payment processing and loan enforcement and may also collect information about you from them from time to time. (see below for more details on third party disclosures).

(c) Data we collect/you upload from your activity across our Services and loan applications:

We will collect process and store information about you that is provided by you, or collected automatically by us, when you use our Services, explore our Services, or interact with other users or us. Examples of the data we will gather related to these activities includes:

  • Any information you populate your Borrower profile with including any images;
  • Any messages that you send or receive through our sites, any customer support enquiries we receive from you by other means, any correspondence we have with you, any participation in user surveys or competitions and any feedback provided to us;
  • A record of your activity including postings to our Forums or other areas of the Service;
  • Details of any transactions that you carry out, including any information we require to provide the Service that you sign up to;
  • Any information you provide to support an auction process, or loan application;
  • Your location according to the IP address assigned to your computer machine or mobile device by your Internet Service Provider, and mobile location data (see more details below – Information we collect about your location)
  • Usage data about how you use our site, this is what we consider Anonymous Data, which we collect using Cookies (see more details below – Our Cookie Policy)

(c) Information we collect about your location

We can collect location data from your computer and/or mobile device. When accessing the Services from a mobile device you will be given the option to allow location sharing with our application. If you do not wish to share your location data with us please turn off this feature by following your mobile device instructions to do so. We can track your IP address if you are using a computer to access the Services. If you are using a mobile device we use GPS with an accuracy range of 20 to 100 metres. We also use your location data to research our own Services, develop new products and improve our Services, including using third parties to help us either provide the Services to you or develop new ones, and target advertising to suit your user experience.

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4. How we use your information (borrowers)

We process data we collect from you for the following core purposes, to:

  • grant you and allow you continued access to our Services;
  • check Borrower credit history/scores, review Loan applications and apply a risk rating;
  • check and validate Borrower and applicant identities including all directors,shareholders, members and partners if applicable;
  • administer your account;
  • administer and enforce loans;
  • help us improve the structure, layout and usability of the Services;
  • allow you to participate in any interactive features of the Services;
  • help personalise your repeat visits to and usage of the Services;
  • provide notices and demands to you, and to communicate with you about your
    account;
  • provide you with information on products or services or news and offers that
    you request from us;
  • answer any questions you may raise or respond to any comments you may send to us;
  • notify you about changes to our service or the functionality of the Site;
  • carry out market analysis and research;
  • ensure that you are complying with the terms and conditions of use and to
    comply with our and your statutory and regulatory obligations;

(a) Credit reference agencies

For the purposes of this clause, Borrowing Parties means any individual or entity financially associated with Borrower, including directors, shareholders, members and partners.

We will check information about you and the Borrowing Parties, and the business of Borrower, held on our own records and also obtain information from credit reference agencies about you and Borrowing Parties’ personal credit behaviour and personal credit accounts.

You expressly agree, and authorise us to conduct a check with Creditsafe or any other credit reference agency for the purposes described throughout this policy, on Borrower and Borrowing Parties.

You, as Borrower and on behalf of and with consent of Borrowing Parties, hereby agree and accept the following statement of authorisation:

“LendingCrowd may undertake a search with GBGroup for the purposes of verifying my identity. To do so GBGroup may check the details I supply against any particulars on any database (public or otherwise) to which they have access. They may also use my details in the future to assist other companies for verification purposes. A record of the search will be retained.”

These third party agencies may add details of our search and your application to the records they hold on you, whether or not your application proceeds. We may also add details of how your agreements or accounts operate with us to these records including any default or failure to keep to the terms of your agreement and any failure to advise us of a change of address where a payment is overdue.

Credit searches and other information provided to the credit reference agencies and fraud prevention agencies about you, and those with whom you are linked financially, may be used and disclosed by such agencies to other companies unrelated to us for the purposes mentioned above. Credit reference agencies will also use the information for statistical analysis about credit, insurance and fraud.

For the purposes of this application you may be treated as financially linked and your application will be assessed with reference to any “associated” records. An “association” between joint applicants and/or any individual identified as your financial partner will be created at credit reference agencies, which will link your financial records. You and anyone else with whom you have a financial link understand that each other’s information will be taken into account in all future applications by either or both of you. This linking will continue until one of you successfully files a ‘disassociation’ at the credit reference agencies. Information held about you by the credit reference agencies may already be linked to records relating to one or more of your partners.

If you would like details of the agencies from which we obtain and record information about you, please contact us.

You accept and understand that we may provide all necessary information to recovery agents to enforce repayment of any loan in event of missed payments or defaults, and to Creditsafe or other credit reference agencies. This may adversely affect the Borrower and Borrowing Parties’ ability to obtain credit in future.

(b) Fraud Prevention

We will also search at fraud prevention agencies for information on your business, the Borrower and Borrowing Parties.

Additionally, if false or inaccurate information is provided and fraud is identified, details will be passed to fraud prevention agencies. Law enforcement agencies may access and use this information. We and other organisations may also access and use this information to prevent fraud and money laundering, for example, when:

  • Checking details on applications for credit and credit related or other facilities;
  • Managing credit and credit related accounts or facilities;
  • Recovering debt;
  • Checking details on proposals and claims for all types of insurance; or
  • Checking details of job applicants and employees.

We and other organisations may access and use from other countries the information recorded by fraud prevention agencies.

(c) Other disclosures of Borrower/Borrowing Parties’ information to third parties

We may be required by law e.g. through potential or actual litigation, court order, public or governmental authorities, or rules and regulations within or out with your country of residence to disclose all or part of your information to third parties. We may also deem it necessary to make such a disclosure in the event of an issue of national security, law enforcement or other such similar situations as we deem necessary including, for example, allegations of alleged infringement of copyright, trade marks or other third parties’ rights.

We share your personal information with third party service providers in order to provide the Services to you including third parties who assist us with information processing, credit and payment processing, fulfilment of your account, managing and hosting data, conducting consumer research or satisfaction surveys. These disclosures relate to providing our Services, improving our Services and delivering targeted advertising to you.

We do not provide your contact details to third parties for direct marketing by them to you without your express consent.

As we continue to develop our business, we might sell or buy assets. In such transactions, the information we have collected about you will generally be one of the transferred business assets. Also in the unlikely event that any of our Group Companies or our assets are purchased, your information will also be one of the transferred assets.

We may share information about you with: other companies in the same corporate group as us, a buyer or prospective buyer of our business, our professional advisers, such as our lawyers, where it is necessary for them to advise us and any other persons if we are under a duty to disclose or share your information in order to comply with any legal obligation.

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5. What information we collect about you (lenders)

We may collect and process different types of information about you. Some of this data is considered to be Personal Data (that means you can be identified by it including Sensitive Personal Data) and Anonymous Data (that is data that you cannot be identified from).

(a) Information we collect when you sign up to our Services and make Loan applications

For all Lenders we will collect your personal details including but not limited to your real name, user name, address, telephone, email address, date of birth, bank accounts and any other information you submit when you create a Lender account and participate in auctions.

You warrant that all information so disclosed is true and accurate.

(b) Information we collect from third parties about Lenders

We may collect information about you from third parties to verify your identity and for fraud prevention. We use third parties such as sub-contractors in technical functions, payment processing and loan enforcement and may also collect information about you from them from time to time. (see below for more details on third party disclosures).

(c) Data we collect/you upload from your Lender activity across our Services and auctions:

We will collect process and store information about you that is provided by you, or collected automatically by us, when you use our Services, explore our Services, or interact with other users or us. Examples of the data we will gather related to these activities includes:

  • Any information you populate your Lender profile with including any images;
  • Any messages that you send or receive through our sites, any customer
    support enquiries we receive from you by other means, any correspondence we have with you, any participation in user surveys or competitions and any feedback provided to us;
  • A record of your activity including postings to our Forums or other areas of the Service;
  • Details of any transactions that you carry out, including any information we require to provide the Service that you sign up to;
  • Any information you provide to support an auction process, or loan completion;
  • Your location according to the IP address assigned to your computer machine or mobile device by your Internet Service Provider, and mobile location data (see more details below – Information we collect about your location)
  • Usage data about how you use our site, this is what we consider Anonymous Data, which we collect using Cookies (see more details below – Our Cookie Policy)

(d) Information we collect about your location

We can collect location data from your computer and/or mobile device. When accessing the Services from a mobile device you will be given the option to allow location sharing with our application. If you do not wish to share your location data with us please turn off this feature by following your mobile device instructions to do so. We can track your IP address if you are using a computer to access the Services. If you are using a mobile device we use GPS with an accuracy range of 20 to 100 metres. We also use your location data to research our own Services, develop new products and improve our Services, including using third parties to help us either provide the Services to you or develop new ones, and target advertising to suit your user experience.

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6. How we use your information (lenders)

We process data we collect from you for the following core purposes, to:

  • grant you and allow you continued access to our Services;
  • check and validate your identity;
  • populate the Key Contract Terms of any Loan Contract, and to notify
    Borrowers of your name and other details if so required;
  • administer your account;
  • administer and enforce loans;
  • help us improve the structure, layout and usability of the Services;
  • allow you to participate in any interactive features of the Services;
  • help personalise your repeat visits to and usage of the Services;
  • provide notices and demands to you, and to communicate with you about your
    account;
  • provide you with information on products or services or news and offers that
    you request from us;
  • answer any questions you may raise or respond to any comments you may
    send to us;
  • notify you about changes to our service or the functionality of the Site;
  • carry out market analysis and research;
  • ensure that you are complying with the terms and conditions of use and to
    comply with ours and your statutory and regulatory obligations;

We will search at fraud prevention agencies for information on Lenders.
Additionally, if false or inaccurate information is provided and fraud is identified, details will be passed to fraud prevention agencies. Law enforcement agencies may access and use this information. We and other organisations may also access and use this information to prevent fraud and money laundering, for example, when:

  • Checking details on applications for credit and credit related or other facilities;
  • Managing credit and credit related accounts or facilities;
  • Recovering debt;
  • Checking details on proposals and claims for all types of insurance; or
  • Checking details of job applicants and employees.

We and other organisations may access and use from other countries the information recorded by fraud prevention agencies.

(b) Disclosures of Lender information to third parties

We may be required by law e.g. through potential or actual litigation, court order, public or governmental authorities, or rules and regulations within or out with your country of residence to disclose all or part of your information to third parties. We may also deem it necessary to make such a disclosure in the event of an issue of national security, law enforcement or other such similar situations as we deem necessary including, for example, allegations of alleged infringement of copyright, trade marks or other third parties’ rights.

We share your personal information with third party service providers in order to provide the Services to you including third parties who assist us with information processing, credit and payment processing, fulfilment of your account, managing and hosting data, conducting consumer research or satisfaction surveys. These disclosures relate to providing our Services, improving our Services and delivering targeted advertising to you.

We do not provide your contact details to third parties for direct marketing by them to you without your express consent.

As we continue to develop our business, we might sell or buy assets. In such transactions, the information we have collected about you will generally be one of the transferred business assets. Also in the unlikely event that any of our Group Companies or our assets are purchased, your information will also be one of the transferred assets.

We may share information about you with: other companies in the same corporate group as us, a buyer or prospective buyer of our business, our professional advisers, such as our lawyers, where it is necessary for them to advise us and any other persons if we are under a duty to disclose or share your information in order to comply with any legal obligation.

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7. Marketing and publicity

(a) Our rights to use any content you upload for our own marketing purposes

By posting information or content including but not limited to copyrighted content, name and likeness and photographs to your profile pages or any public area of the Services, you automatically grant, and you represent and warrant that you have the right to grant to us a non-exclusive, royalty free, worldwide licence to use, copy, publish, display, reformat, translate and distribute, and broadcast, such information or content and to grant and authorise sub-licences of the same. You further waive any moral or potential infringements rights you may have in any such information or content.

Specifically please note that we may use any of your content, including your photographs and business description, loan request summary, for the purposes of advertising or publicity in various ways including case studies on our websites and other marketing materials. If you do not wish us to do this, please contact us.

(b) When we market to you directly about our products and services

We may share your information with our Group Companies to develop and deliver targeted advertising to you of our own and our Group Companies’ products and services, or to help us to prepare marketing reports. We may send you information about our Group Companies’ products and services, news and offers, and selected third party products and services that we think may be of interest to you. We may do this by contacting you through your email address or mobile phone number that you have provided. Any communication received from us, as consented to by you, will clearly state that it is being sent by us. You have the option to opt-out of our marketing communications at any time (see below).

(c) Opting Out of Marketing

If you change your mind about the marketing consent you have granted to us, you can amend your consents by contacting us.

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8. Where we store your data

The personal data that we collect from you may be transferred to, and stored at, a location outside the European Economic Area (‘EEA’). It may also be processed by law enforcement agencies, employees and independent contractors of our Group Companies located outside the EEA who work for us or for one of our suppliers (for example, staff who are involved in providing services that you order from us, processing your payment details or providing support services to us).

By submitting your personal data to us, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

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9. How long we keep your data for

Generally speaking, we only store data for as long as it is necessary to provide products and Services to you and others. It is important that we retain your data for so long as you are using the Services, and until any loan is completed and repaid fully. Even after cancellation of your account we will require to ensure that we can provide information to third parties in line with our disclosure provisions outlined in this policy e.g. assisting police investigations and anti fraud measures. For this purpose we will hold only the necessary data for 6 years.

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10. Keeping your data secure

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Site; any transmission is at your own risk. Once we have received your information, we will use procedures and security features to try to prevent unauthorised access. Where we have given you (or where you have chosen) a password or user ID which enables you to access certain parts of the Site, you are responsible for keeping the password or user ID confidential. We ask you not to share a password or user ID code with anyone.

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11. Our cookie policy

We may collect information about your computer or mobile device by using Cookies. If you use our site you are consenting to the use of Cookies as explained here. Cookies are small text files that are placed on your computer by websites that you visit and provide statistical data to us, that does not identify you personally but an tell us a lot about your browsing habits to tailor your user experience to suit your needs. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. We use cookies to enhance our security, help us gather information when you use our services and understand our web traffic trends and to share your non-personal information with carefully selected third parties for marketing purposes.

Cookies help us to improve the Services and to deliver a better and more personalised service. They enable us:

  • To estimate our audience size and usage pattern;
  • To store information about your preferences, and so allow us to customise
    the Services according to your individual interests;
  • To speed up your searches;
  • To recognise you when you return to any website or application;
  • To provide annoymised statistical information: Non-personal data may be
    gathered on our behalf using cookies, log file data, and code that is embedded on our websites by specific third party partners to help these selected third parties to deliver relevant advertisements to you.

We use this non-personal information to help improve the services we provide to you. When you visit the publicly available sections of the Services, a session ID cookie is placed on your computer that only lasts while you’re visiting. We also place persistent cookies (also known as local storage devices) on members’ computers, so that we remember them to make your login in process faster and easier.

(a) Controlling and deleting cookies

You have the right to choose whether or not to accept cookies and we explain how you can exercise this right below. However, please note that if you choose to refuse cookies you may not be able to use the full functionality of our Sites and the websites of other companies. You may block cookies in several ways:

You can also block cookies by changing your browser settings so that cookies from this Site cannot be placed on your computer or mobile device. In order to do this follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” facility). Disabling a cookie or category of cookie does not delete the cookie from your browser, you will need to do this yourself from within your browser. Further information about cookies, including how to see what cookies have been set on your device and how to manage and delete them,
visit www.aboutcookies.org and www.youronlinechoices.com.

(b) What cookies are used for and why we use them on this Site

This table shows fully the cookie functions and why they are used, although our uses may change over time and it is important that you revisit this page to understand these uses:

Cookie Functions Cookie Purposes
Analytics and research We may use the information collected by Google Analytics to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. You can opt-out of Google Analytics here
Authentication These cookies help us to identify our members so that when you’re logged in, you can enjoy all of the features without having to continually log in – our website “remembers” you and allows you full access without the need to keep entering your log in details.
Security and site integrity We may use cookies and other devices, such as CAPTCHAs, to help keep the Site and our members safe and secure by protecting the Site from fraud and spam attacks to keep your data safe.
Site features and services These cookies and local storage devices provide the functionality that our members enjoy, such as uploading of photographs, chats, instant messaging, your account settings etc. We also use cookies to help provide experiences, such as links to other social media sites, social plugins and video content, including making it easier for you to share content between the website with your other favourite social networks. In some cases, the site feature you choose may allow a third party to place cookies or local storage devices on your computer. The third party who places cookies on your device is responsible for how they process their data you should always read their privacy policies. Third parties who place cookies on your device when you use the Site include Twitter and Facebook whose own privacy policies apply.
Performance We need to use certain cookies and local storage devices to ensure our members have the best possible experience, such assisting with your navigation of our site, ensuring pages load up quickly and respond faster to your requests for our Services.

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12. Our rights to amend this policy

We keep our privacy policy under regular review and will post any changes to it on this page. We encourage you to regularly review our privacy policy to make sure you are always aware of what information we collect, how we use it and under what circumstances, if any, we may share it with other parties. We may also contact you from time to time to advise of any changes if we feel such notification is necessary depending on the extent of the changes, or post a notice within the forum area of our websites.

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13. Links to other third party websites

Our websites, apps, and promotional materials, may, from time to time, contain links to and from the websites of our third party networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

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14. Additional privacy protections for children using the internet

We do not solicit or target persons younger than legal age for collection of information online. Our Site does not permit children under the age of 18 to become users and we do not accept any information from children. By submitting information to us you represent that you are over the age of 18. We encourage minors to seek the consent of their parents before providing any information about themselves or their households to anyone on the Internet. We encourage parents to take an active role to protect the privacy and security of their children and to prevent the inappropriate use of information about their children. We support the development of technologies that help parents to control the collection and use of personal information from children who use online services in their households.

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15. Questions

If you have any questions about this privacy policy then please contact us for more information or clarification.

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If you invest through LendingCrowd you should understand that as a lender, your capital may be at risk.

LendingCrowd is the trading name of Edinburgh Alternative Finance Limited, Company Number SC468392, authorised and regulated by the Financial Conduct Authority (Firm reference number 670991). LendingCrowd and its products are not covered by the Financial Services Compensation Scheme.

Read more about the risk involved when investing and borrowing.
LendingCrowd is a credit broker and not a lender.

The company's registered office is 23 Manor Place, Edinburgh, EH3 7DX.

Copyright © LendingCrowd 2017. All rights reserved.

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